The Audit Approach: Focus on Implementation

Elizabeth Tierno: We are very excited to be here and to talk with you about the audit approach and the focus on implementation. and there's always that trick of how do you get the sites involved that are from the very new, maybe they're just considering certification and the sites that have been here for years and years. And we're hoping that we've got a mix of a blend of that to keep everybody engaged and so that everybody can learn something today. and before we get started, we have to talk about our antitrust statement. so this is something that we have to do for every presentation. and we need to make sure that our topics, that our conversations stay on topic. So, we're not going to talk about any price fixing, boycotting, trade restrictions, any of that, anything of that nature. but we will talk about food safety. food safety is a very safe topic, and that's what today's going to be all about. but if you think that the conversation gets off topic and does violate the antitrust statement, please do say something and we can stop and redirect the conversation.

We'll just Okay. so, a little bit about who I am. my name is Elizabeth Tierno. I've been with SQF now 2 and a half years. The time has just flown by. prior to coming to SQFI, I've worked in the food manufacturing business. so I've worked for many different SQF certified sites. I have a background in dairy and beverage, bakery, and honey processing. so I got a little bit of all of it mixed around. I do tell people I do not have any experience in meat. I intentionally stayed away from meat. So anybody who does have that, I applaud you. I've heard horror stories. I don't know if they're true and I didn't want to find out. but that's a little bit about my background and my experience. Denise, how about you?

Denise Webster: Yes, thank you, Elizabeth. hello everyone and thank you for joining us today. my background is in manufacturing. I've also spent time in CPG land commercializing brands as well as the retail space heading up food safety and regulatory. currently I oversee the SCS training and consulting department. so I'm out there helping lots of many different very small to very large businesses understand food safety implement and maintain kind of that progressive proactive approach. so I'm excited to partner today with this webinar and Elizabeth and share with you guys more of what's going on out there in the world and how you can better prepare your team.

Elizabeth Tierno: Awesome. Thank you so much, Denise. So, talking a little bit about our agenda, what we're going to cover today. So, before I dive into that a whole lot, the first thing is their industry update and SQFI insights. so for anyone who has who gets our newsletter, you heard today that hot off the presses that edition 10 is going to be published in March. So for those of you who don't have the newsletter and you might be scrambling going, how do I sign up? So it might be a good idea try and get signed up. But edition 10 will be released in March. implementation is going to be at least 9 months later. So don't panic. It's not like you have to do it right away. it will be no earlier than January 2027. So just keep that in mind. this webinar is not about Edition 10. I will talk about it a little bit at the end. so just keep that in mind but we're not going to discuss Edition 10 today. but what we are going to discuss are some different practical tools. So what kind of training or different things can you have to help build an effective food safety program? So, it's all what we're about.

How do you have that effective program and what it looks like for one site? It's not going to magically just work for another. Everyone's going to have a little different and what tools do you need? What training might be effective for your facility. and then different techniques that you would use specifically looking towards like internal auditing and how we train people in internal auditing by using different observations and interviewing practices. and then different tips. So, what kind of management commitment do you have? Where is your food safety culture? And what does that mean? And how does that affect your program? And how does that affect the implementation of your program? There's so much of that you need to have all together. so we're going to talk about all those as a whole. and the pieces that go into that.

Denise Webster: Thank you, Elizabeth. So, we thought it might be prudent to speak to a global perspective. SQF is a global code and although I know, we're I'm US-based and spend a lot of time here in North America, we really do share the same types of concerns globally that we need to focus on. Over the past few years, we've seen continued change and escalation of those challenges in that impact the food industry, requiring us to be more aware of what's going on outside our four walls of manufacturing. We have emerging hazards such as an increased focus on heavy metals and PFAS and having to elevate our testing programs to be more proactive, including identifying potential food fraud risk associated with that category. We've also had a wakeup call on radiological concerns. If I asked many people a year ago, do you think radiological concerns are a concern in your hazard analysis plan? Many of us would say no, not likely.

But then we found cesium 137 in frozen shrimp products due to industrial activity and not just due to a mishap, but processing scrap metal at an Indonesia facility resulting in airborne release in the area. We've also seen an emerging ransomware and other cyber attacks on food companies. Some reports indicate the risk has doubled in the food industry. So we need to become aware and this is part of our crisis management protocols looking at the risk in putting programs in place to ensure that we can protect in the event of or prevent it from occurring at all. Even more important because we continue to expand the use of our technology and electronic data capture for the processing operations in our facilities. Lastly, our fellow supply chain partners who purchase the ingredients and ship the products that we ensure are food safe and of optimal quality. Well, we need to support them as food safety professionals.

We need to play a key role in pre-identifying potential challenges with them, create adequate vetting of suppliers, and creating those checks and balances to ensure continuity of a safe supply chain. Ultimately, adopting a standard such as SQF creates that foundation, but it's up to us to fully develop, implement, and be ready for that change. So, really today, we don't have a new code in front of you, as Elizabeth said, but what we can do is start getting ready and put putting on that more proactive change management mindset. and we're going to cover some tools today and tips that hopefully you'll be able to kind of gleam some key takeaways of things to work on now before March.

Elizabeth, so one thing that SQFI does provide is a smart brief and in that smart brief is kind of a collection of different things globally of what's going on, different articles, so you don't always have to hunt and search and try and see what is new and what is out there. but we try to provide just a quick snapshot of that and there are so many different places of resources. because we know that time is of essence and it's it's sometimes so hard. You're I just don't have the time. I've been in the manufacturing world. I completely understand when you're going, I don't have the time. You're not making it up. and you can't create time. But we can try and give you those things straight to your email. and then you can sign up and you can get it twice a week and just say, "What are the articles? What is emerging?" and that way it's it's right there at your fingertips.

Denise Webster: Exactly. And we do have so many more tools than we ever had. One of those is the FDA data dashboard. it does look at, a segment of the industry, specifically the US and those products under the jurisdiction of the FDA. But we can use these tools to be able to understand what's going on and be able to proactively address and reduce those risk in our overall business. Specifically, the FDA data dashboard, if you haven't been on it, does look at also inspections going on at any facility that has been inspected by the FDA or has been impacted by recalls both globally or domestic and foreign that sell into the US. So, check it out if you have not. we've been able to pull the 2025 data for the US recalls specifically for that food. and unfortunately has cosmetics in that still, but we've kind of helped strip those out. And we can see unfortunately in 2025 we've continued increasing our recalls. so we still have a lot more work to do when it comes to being more proactive as this is a lagging indicator.

This is the post of us not being able to fully address this before product gets out into the marketplace. So let's take a deeper dive into that. Class one, we did analyze the data. The nice thing about the data dashboard is you can export it into an Excel or CSV file and be able to run, certain reports and really look at the information. And what we found is that Salmonella and Listeria in 2025 had the large proportion of class one recalls. A majority though of Salmonella, it's a little skewed driven by things like the cucumber recall that then was impacted because it went into other ready to eat products due to though an identified outbreak. So it did not just start with a finding at a facility, it was a outbreak related issue. equally Listeria monocytogenes recalls driven by ready to eat meals and sandwiches.

A lot of the information that we're gleaming is becoming more available at a CDC level when it comes to outbreaks and diving deeper. although it's still difficult to find exactly where these issues are happening and they do their best and out of the abundance of caution sometimes have to recall the products even though they may be safe and not impacted. Allergens close behind. interesting though with allergens this year when I looked at what was actually recalled for allergen mislabeling it was egg and milk that was leading this year. so I thought that was interesting. Although sesame and tree nuts are still showing up fairly strong in that 20 28% numbers. Other challenges you can see with that elevated heavy metal risk. specifically there were findings that had lead levels in sliced pears and juice and some herbal powders. there's also was an elevated contaminant in fish and in pumpkin juice. And then the additional sliver there of foreign material. Usually we see foreign material as class two recall the metal plastic unless it is a choking hazard.

And then and specifically a choking hazard that might be to those at risk population. So this one particular one was infant choking for teething snacks. why is this important to learn? it's really and us to be able to proactively reduce our risk by what's going on in the broader industry. Okay, Elizabeth, over to you.

Elizabeth Tierno: So, here's a chart of what SQF certified sites what we're seeing over the last couple years. as you can see, the 2025 data is through August. we are still sorting through all the information that we've gotten. we definitely encourage our sites that we would rather have the notification ahead of time and then find out, hey, we didn't need to notify you versus we don't get the notification and then we're scrambling and trying to find out the information later. So, we do have to sort through a lot of that information because we do get over notified and again we much prefer that way. it just takes us a little while to get those data. so that information for 2025 is through August. so we expect those numbers to grow. the definitely that stand out there is for biological for 2024 we had a huge increase. and like Denise was mentioning it's that one site and that one site is a supplier and they supply to 20 different sites and then it just slowly impacts so many different people.

So that was part of it and the problem was it wasn't just one of those but I think there was like three of those last year. So, it really jumped out those numbers. and I wouldn't be surprised if the numbers for 2025 end up being close to those. for what we're seeing for SQF certified sites, the top numbers for each biological, chemical, and physical categories are the same. So, Listeria monocytogenes and Salmonella, I want to say always, maybe always isn't the right word, but they're always at the top. Those are the top two. and they do occasionally switch back and forth of who is the front runner. I'm not sure if that's a winner or a loser. but for that year, but they are definitely our top two that are always getting called out. and for some reason we're seeing milk and wheat. So I did see quite a few egg also on SQF certified sites. but wheat we had a couple more recalls with rec this with wheat this year than with egg. and for physical it's it's always seemingly plastic and metal. You do have a little bit.

Sometimes there's glass, plastic or glass and wood mixed in there, but plastic and metal are the most prevalent. so we'll see. like as I said, we do get that over notification, but if you're a site and you've initiated your recall program, so it doesn't mean that the recall happened at your site that you caused it, but if you've had to initiate your recall program, so maybe it's your supplier supplied something and they have to recall something, but now you have to initiate your program because it's left your control. you're required to notify SQFI and your certification body. so keep that in mind. We are finding that there are sites going, "Oh, I didn't know." So, don't be caught not knowing. If you've initiated your program, you need to notify. And as I said, we would much rather have that over notification and then get that email two weeks later that says, "Never mind, the recall didn't happen. We didn't have to notify you." So, please over notify us. and we will deal with that and sorting through that information.

Denise Webster: Yeah, that's a great reminder, Elizabeth, because I do believe it can result in a nonconformance on your audit as well if you haven't properly done your notification.

Elizabeth Tierno: It can, and we do have sites that get that nonconformance.

Denise Webster: Excellent. Thank you. So, let's take a look at some key preparation pillars. really the number one key thing that anybody needs to do when implementing change is having a good foundation of knowledge. So that's going to involve training. that'll be training against the new code when it comes out for the SQF practitioners and those key stakeholders within your organization and the ability then to also transfer that knowledge within the teams. and sorry Elizabeth I realize this is your slide. Not a problem. Go ahead. Yeah. And so internal audits, if you would like to speak to that, those last two as well.

Elizabeth Tierno: Yeah. So just to touch on that training, it's not so much you just sit in a classroom and someone talks to you and go, "Okay, I got this. Can you implement it? Can you actually put it into practice of what you've been trained or we I worked in operations and you're 24/7. Can you train someone who's on third shift and they were just about asleep?" So you can check the box that you trained them, but it wasn't effective. internal audits, we often see that sites, they think they're doing it correctly, but they're not. They're missing the mark a little bit. So we're going to touch on that and what that means. and how to do it effectively and correctly. and then management commitment. so important.

You have to have your management on board. and how that's so important with significant changes whether that's a code change maybe it's not a code change I mean yes we are doing that and that is coming and that is a huge piece of my world right now but what other changes are going on at your facility and what does that mean and how do you have to put that into practice on a daily basis even when the code doesn't change maybe it's not us maybe FDA has changed something or CFIA or whatever country you're located in. Are there some regulatory problems or changes that happened that you have to be aware of to fully implement and how do you put those into practice at your site?

Elizabeth Tierno: All right, I think this one is also mine. so it's all about that team change of mindset. You have that change. and it's about getting everybody on board. It's not that one person. regardless if you have five people at your site or 500 people at your site, how do you have that mindset for your team? And the team cannot be that one person you're going, okay, how do we get everybody on board to understanding what is our next thing? What are our next steps? and how do we evolve and adapt these? if you stay stagnant, you're not going to be successful. going, okay, businesses are constantly changing. The market is changing. We talked about recalls and how that market has changed. And if you're not aware of it, you're going to miss something. but you we have a clear purpose.

You need to make sure that it's communicated effectively to your team. so if they're not understanding what the change is, they're not going to understand how it impacts them and what changes that they have to do or how it affects their daily routine, their things that they're on the production floor doing. how it aligns with organization goals. Can you get the top of the company as well as the bottom and they all work together? If you work towards the same goal, you are much more successful at meeting that goal. and whether it's a short-term or long-term, it does have lasting impacts when the whole team is going in the same direction. my family is huge sports fans. so whether it's baseball or football, but you look at the team and if the team's not all working for the same goal, they're not successful. they're not going to have a successful season. They're not going to win the game.

So how do you get everybody on board working towards that same goal? and talk about leaders. so whether it's the management, your supervisor, maybe it's a line leader. how do they have that support whether supporting their teams and also support for them? they all have to be visibly on the same page. There are definitely a difference in opinions and everyone's not going to agree. but how do you get on the same page and work towards that change mindset of moving forward and achieving that? again that consistent messaging. If you have one supervisor say one thing and another one say another, you're going to confuse the people on the floor. And the more confused they are, they're not going to have that same adaptation, that change mindset. They're going to be just confused and going, I don't even know what I'm supposed to do. So, that's a huge distraction with trying to implement whatever it is. whether it is a code change, maybe it's a new GMP that you have and how do you get everybody on board or if they don't know the whys, right?

They don't realize no, you haven't told them the code is changing or that there's an a reason why and they're just having to kind of follow the rules. So the importance of that consistent reasoning as well to get their buying and commitment. Absolutely. And then I know your audience there are some people I'm I'm very much a why person. You tell me why it needs to happen and I'm much more inclined to go okay now I can understand the why so I'm more willing to adapt that change versus just telling me that I have to do something different. So absolutely that's a very good point. and you have to have resilience and problem solving when you do change. as much as we would like to think that we live in a perfect world and things are going to happen the way they're supposed to, that's not how real life works. that you're going to run into problems, run into those glitches along the way. And how do you solve those problems to continue to move forward and to keep to trying to do that change and implement it?

Denise Webster: So, we're going to open a poll here. we'd love to hear about what is your biggest challenge your team faces when adapting to change. this is a rank one being the highest of the four that we've selected there, four being the lowest. if there is another one that really speaks to you that we didn't quite capture in those four bullet points, please add that to the comment field and we'll take a look at those later and kind of discuss those and see how we can help you all adapt to change and reducing some of those hurdles.

Elizabeth Tierno: So Denise, there is that chat button or QA button at the bottom. So go ahead and you can put comments or questions to us there. it says host and panels cannot vote. I think someone needs to open it up. Oh, it's Oh, for me I can't vote. Okay, it's voting. Ah, I see it now. Okay, perfect. We'll give you guys a few more seconds. Right.

Denise Webster: Okay. So, we'll go ahead and got the pole number. So, it looks like I'm just trying to interpret here. It looks like the highest one obtaining alignment with others and kind of leading the pack both one and twos. thoughts on that Elizabeth in terms of what are some of the ways that we could get alignment from others?

Elizabeth Tierno: I think that goes with the slide that we just had that change mindset of can you get the people on board going okay how do I get there I know what I need to achieve and it does depend on your audience is it your production is it quality is it your management going we need to get aligned and we're not I had a CEO that she was very much a why and I needed to be able to answer that and then she was okay but there was a lot of resistance if I couldn't answer the why we needed to do something but be open to other options. So if you only have this one way and you go this is the way we have to do it, be willing to listen to what they have to say cuz while the goal should be there, sometimes there are different routes to get there and to be open to listening to the other ways to get there will help align and get that people going. Okay, now there's more buy-in. You've heard my voice and maybe you disagree. there's a reason to say I appreciate your feedback.

I see some challenges and maybe this why that route wouldn't work. but listen because as I was a manager for a while and I had an employee who had been there say maybe 3 weeks. She's like what if we tried this I didn't I didn't think about that. Let's try it. And it worked. So be open to those other routes. it would be a huge buyin for just about anybody.

Denise Webster: Yeah. And close behind that is resistance or fear of the unknown. And I think that can lead into a lot of different hurdles because if they don't know the whys like we talked about or if senior management commitment senior management hasn't come out and said this is what we're doing. This is aligned with our vision and our mission then it's only one person trying to get alignment or change. And so all of those have to come together really in order to make that impactful shift. whether well it might be micro shifts, it could be macro shifts that need to happen in any given category of what we're trying to achieve to reduce those risks.

Elizabeth Tierno: I am happy to see that the highest number for four is leadership not supporting change. Yeah, that's a good definitely a good call out that most leaders for you guys are willing to support the change and try to move forward. So that is a good thing to see.

Denise Webster: Yeah. Yeah. Yeah. And I think the big thing to do too is to keep them constantly informed of those things that they need to support and speak to. So it's coming from multiple voices.

Denise Webster: Okay. Excellent. Well, we're going to take a look at those pillars. so here's where you can start taking some additional notes and hopefully gain some a little bit more value from this webinar in terms of some key takeaways. so when we look at training and why it's so important ultimately it's very much what we just spoke about. We need to first obtain that knowledge and then we need to make sure we've communicated that knowledge whether it's a change in perspective. for example FDA FSMA has updated their preventive controls for human food to version 2.0. If you've taken the prior version I'd encourage you to take the new one. you're going to obtain new knowledge and as adult learners we need to get additional reinforcement and then we need to get others trained. same with when the SQF code comes out implementing or the conversion training. We also need to look at more of topic specific training or those onepoint lessons. Do we really understand what food defense is and how to protect not just the outside threat but the threat inside attacker a threat?

Can we conduct effective risk assessments or we try and apply the same risk assessment to different topics when really it requires a different approach and we'll talk more about internal audits but ultimately those internal auditors need to be internal audit trained. another topic is don't forget that it's not just about our technical skills. We need to elevate our training when it comes to our leadership skills and our personal development skills. If we haven't already and 2025 set our goals personally for the year, set them as well from a professional personal development standpoint. Where do you need to help yourself grow and the business grow? Maybe it's financial acumen, emotional intelligence. All this will help be better food safety professionals. Attend webinars, conferences, and trade events are also a great way to obtain that knowledge and what's changing out there.

As we spoke about those global impacts and newsletters and regulatory updates specifically to the country of your manufacturing operation to those countries where you may be buying ingredients from or selling to. So just to tag on that understanding that sometimes there's that financial piece of how do I get that training? I can't get approved for it. There's a lot of free things out there. so don't make that a hindrance of why you can't do it. There are things you just have to look for them.

Denise Webster: Yeah, LinkedIn has some YouTube videos. even check with your own HR. they might have access to items as well through their learning development team. So once we have the training, we have to communicate out as part of SQF practitioners. We all know that is one of our main responsibilities not just to oversee but communicate to key department heads and senior leaders the understanding of those changes and the areas of improvement needed. So that's going to be something you're definitely going to want to queue up when the code does launch. We also then need to develop a plan. It's one thing to understand what's changing, but what is that plan? what are those task and activities and what is the timeline associated with that and communicating that to the relevant team members. It's not something we're just going to protect in our own little world. We're going to communicate that out and pri provide the education and tools to ensure confidence in those new changes or updated processes or where we need to really take a different approach altogether.

Another great way to communicate to key stakeholders, those frontline employees, they need hands-on learning and coaching. It's not one and done. It's not a PowerPoint presentation or sticking them in front of a computer. It truly is involving learning and coaching. Elizabeth shared an example and I'll share an example specifically where we had chemical handling training. we actually took them out and discussed the chemicals and were looking at the chemicals and we showed them how to do a titration and started talking about how effective they are from their perspective and really it went two ways. We need to step up the way we approach training this year in 2025, especially with technology and all the resources we do have in that category and really solicit feedback both ways that really does impact that change mindset. So, we do have to change that format, gain that audience participation, create learning objectives. So it's not about I'm going to deliver a training. What does I do? I want the learners to obtain and take away. What are their expectations of this training?

Going around whenever I do a training, that's the first thing I start with is well, what do you want to achieve out of this training? You're getting that engagement. Then you're also doing the polls or quizzes to understand where they're at, where they think, and that competency check. We can also have applied exercises, demonstrations as I spoke about and just follow through with the post training. It's not we train and then we hope for the best. We do those verification activities. So, one of the things that you could look at is dive deeper into your training programs. Are they effective? Have you been doing the same thing year on year out? Do you have you ever done a train the trainer course?

Sign up for one of those. it gives you a lot of practical tools when we're looking at training adult learners. they state research shows that learners forget an average of 50% of the information presented within 24 hours and then they forget an average of 70% of new information within a week and they forget about 90% of what they've learned. so ultimately we have to look at things where we can increase that acumen such as finding physical activity as short as 15 minutes can improve memory and streamline skill acquisition.

Denise Webster: Okay. Internal audits. Elizabeth, did you want to speak to this before we start? as we can. so internal auditing we talk about that quite frequently at SQFI. we've done different validation audits. so validation audit is typically it's the it's SQFI as well as the certification body go into a site and we're auditing the audit process. So we're not there to audit the site but more the auditor and what they've seen. but we do pull some records specifically as internal auditing and so often we see the sites very proud of what they can show us and we have to be like this doesn't meet the expectation so I need you to read the code so they really think that they're doing it right. So I would encourage you look at your internal auditing. Look at what you did last year and what you did the year before. Did you just sit in a conference room and do your internal audit because if you didn't leave the conference room, you're not doing it correctly. There's so much objective evidence that you need to collect just like your third party auditor.

So, when they come in and do your audit, it's how you should be doing your internal audit and what that means. And we're going to go over those steps of how to be do a successful internal audit.

Denise Webster: Excellent. Thank you, Elizabeth. Yes, it's that Go to RIO which we have documented here and we'll speak more of where we look at the documents checklist and records. Yes, this is that desktop review. We do have to have a portion of our internal audits that involve reviewing your policy procedure work instruction. We need to know the basis for what we are trying to audit. and then we're going to compare and contrast those against records or other things that we see, which we'll talk about in a few minutes. We also need to make sure we have the right checklist, guidelines, and references to ensure that we are comparing appropriately and determining our level of compliance. The first thing you should be doing is developing an internal audit schedule. So, if you haven't developed one, it does it is time consuming. you have to prioritize. It's not about just checking everything in the code once a year. It's taking a look at it from a risk-based perspective.

It's food safety related and it could potentially result in an outbreak recall or a significant nonconforming event, then you're going to want to look at that more frequent and you're going to want to have maybe internal audit on that monthly or quarterly. really evaluating how often you're reviewing certain programs is something that we do need to improve as an industry versus just that annual check the box on all of our programs. We also need to set ourselves some goals and success metrics. Why are we doing this in the first place? Our lagging indicator is did we do a good job on our SQF audit? Our leading indicators are we on track with it through our internal audit process. Are we finding the nonconformances? If your internal audits coming up with no findings, likely you're not digging deep enough. You're not setting metrics for success like we want to find nonconformances because that gives you that opportunity to address those prior to any audit. That's the true implementation success of internal audits.

Also, as Elizabeth mentioned, evaluating your past nonconformances, looking at your prior audit reports, whether it be SQF or your third-party or excuse me, your customer audits or your internal audits. Were there trends? Are there things that you need to do a deeper dive root cause analysis on that can really help elevate not just a program to check the box? And then we have the I interviews. being able to do thorough and engaging interviews is an art form. it takes practice. you need to make sure you're asking open-ended questions versus closed such as just questions such as yes or no. You want an actual answer, but you also don't want to lead them. and this is a great area where we dive deeper in internal audit training to teach internal auditors how to ask questions that really get to their knowledge and understanding of a policy, procedure, or activity that individual is responsible for. We also need to practice the art of listening. Listening to understand and not to answer. listening to understand if what they're saying aligns with our procedures.

Not to find fault or nonconformances per se, but to find what we would call gaps. That could be gaps in our procedure versus actual implementation not matching. And maybe it's the procedure that's wrong, not the actual implementation. We also want to assess competency and where improvements may be made. We're constantly needing to continuous improve change mindset. So being open to finding those gaps in through our internal audit process where we can improve. It might not be necessarily a nonconformance but we could see something that could be enhanced. Ultimately it helps to validate through observations. Share those observations without also blame or focus and focus on the solutions. Elizabeth mentioned asking the employee to provide their ideas for improvement. How can we make this better? That can be part of that interview process. It's two ways also as part of our internal audit that Go to RIO records interviews and observations. observations. What do we mean by this? It means you sit stand and observe people and processes for a longer period of time.

It involves potentially reviewing documents and records and interviews in real time, but observing really helps us understand if it's aligned with our procedure that we're we have the right objectives and expected behaviors. So, we can you can really compare reality versus documentation. One example would be taking 5 10 minutes to hang out around the handwashing station during a shift change. How many people actually wash their hands? Wash their hands for the 20 seconds. Wash their hands with a correct order. you would be surprised it when you stand around for a while and just observe. also follow the flow. flow of your operation, flow of people, different times, flow of equipment. This is vital when you're looking at issues with your environmental monitoring program. Look for bottlenecks, maybe workarounds. As humans, we are crafty and we create workarounds to either make our life better or we think we're finding solutions that maybe are not necessarily approved. that could be gaps or errors as well.

So look for those activities through your observations, not just with our blinders on of checking a foreign material checklist, glass and brittle plastic or a GMP checklist. We're looking for those temporary repairs or specific workarounds that we might identify and then through that obser observation you can loop in those interviews through collaboration and communication. Hey, I noticed, you did this particular activity this way. Describe to me, why that is or what you're doing or I want to learn more about it. so then we can figure out what might be the root cause or the reason for that particular concern also that records match the process actions and are completed. Another example, if we focus on the code allergen management 2.8.1, if I'm going to do an internal audit, then I could use that Go to RIO records interview observations approach, and look at what does the process say and what records are available. Have there been any issues? Right? We want to know what's going on and understand the process.

Then we want to go out there and walk through the operation. talk to the employees and ask them to give you some more information such as well walk me through the steps that you take during an allergen changeover. You can ask them what challenges do they face in completing that process and how do when this area is ready for the next product. These are good open-ended questions. They're not leading. they are giving us the information that we need to understand compliance and where we might need to close some gaps. Then through our observation and training making sure that they're using the correct tools if it's the color code system identify those shortcuts if any skipped steps and those verification activities have been completed and are in compliance.

Elizabeth Tierno: So to tag on to what you're saying about observations, I had one of my SQF auditors and he came down to our production floor and he stood there. I'm not kidding. I'm not exaggerating. It was 20 minutes. We just stood there. We weren't actively going around and eventually. So I was new and I was like, "Okay, I have to ask, what are you doing?" And I was like, "I mean this respectfully, but don't we have stuff to look at?" And he goes, "I'm just watching people." He goes, "It's crazy." He's like, "You walk onto the production floor and everyone quickly turns and they see you and you go, oh, there's the auditor. They're on the floor." He goes, "But 5, 10 minutes, 15 minutes." He goes, "They've all gone back to their normal behavior. They kind of ignore that I'm even here because they see that I'm just standing here." So, like, there must be talking or something and he's just watching. So, it is so important. and it's kind of crazy what you can see. So go and see your employees and just watch them.

And sometimes you have cameras and you can watch on the cameras and they don't even know that you're watching. But see what behavior is, what good behavior is there. Not as like a I got you. You did something wrong. but you can really encourage your people. You're going, "Hey, I saw that you were doing this correctly." and that positive reinforcement goes a long way for people in general. We did have a question that came in about how do you build confidence about your internal auditors and I would say it's it's the same thing. Where's that positive reinforcement? So, how do you verify that they're doing their job correctly of going, okay, they're doing parts of their internal audit and are you reviewing that information? Are you observing what they're looking at? and then positive reinforce that. And maybe it's, we did do a training, but there's this gap that you're just not quite understanding that. Yes, you're getting the main pieces. However, you're missing writing the objective evidence. So, let's show you how I have this.

We'll have this quick webinar. maybe it's a an hour thing, maybe it's a 20 minute conversation, maybe it's a 5 minute thing. There is no time restriction, but sometimes that, hey, we'll have that quick one-on-one conversation goes a long way to going, okay, I did do that wrong and now I understand how to do it correctly. So that positive reinforcement of those things is huge.

Denise Webster: Yeah. And this Go to RIO method, if you want to speak to the guidance documents that SQF has that use this approach that can help their your internal auditors.

Elizabeth Tierno: Absolutely. So, as I said, there are a lot of resources, a lot of free resources. and SQFI has a lot. So, if you haven't checked out our website recently, I would encourage you, please go to our website, check it out. we have many guidance documents and with edition 10 coming out. We are looking to update some things. So, keep that in mind. Look at them now, but look at them a couple months from now also. but what is there? We do have that Road to RIO.

So whether it is for internal auditing or maybe it's environmental monitoring but what is that topic that what we just need a little bit of help maybe I'm reading the code and I'm not sure I'm interpreting the code correctly but go for our website go look at those guidance documents they are very helpful and we do update them so keep that in mind we are updating I think every single one of them is getting updated in the next couple months but yeah check out our website we also have different things on our YouTube page. such things as what we're doing today, we have these different webinars there that you can always so go back and look at. We've recently have done different topics. So go look at those webinars and you can listen and watch those. we also have a certification practitioner credential. which a lot of people don't know and they're not aware of. and that does give that practitioner a little bit of a leg of a stand up and see what's going on and what is out there. Gives them that extra training that they need that confidence to help build them.

So, if you are that SQF practitioner, talk to your site, your ownership, and be like, "Hey, I'm interested in this." and you can always learn more on our website about it. but it is a great program and to build that confidence. and it stays with you. So when you if you would leave your current company, that credential goes with you. and it's it's pretty cool. I'm not currently an SQF practitioner since I work, but if I was, it is something that I would want. and to lead into that is management commitment. so if you guys look at the code, this has not changed from one Edition to the next but management commitment is right at the beginning and there is a reason that the code starts with management commitment because you need that to build your program. so don't take that lightly. I really like that when you guys said that leadership isn't your biggest hindrance. That's huge because if you can get management on board and get them all moving in the same direction, that's a huge building block for your food safety program as a whole.

So take that in that reason that why we have management commitment at the beginning is because it is so essential for your program. Thank you Elizabeth. That's a great tea up for that last pillar of management commitment and even speaking to getting that commitment on that additional training and the importance of being that credentialed SQF practitioner for your site and going through all those steps. ultimately the first thing out of the gate is that mission and vision is aligned. we do need to set that strategy based on not just food safety but that food safety is a core business value of the company. That's why we have that food safety policy signed by the seniormost person in the operation. it's important that our business objectives are not just those that relate to production and output but our food safety. we're going to have ultimately KPIs around the behavior for example from a food safety culture and we'll speak to that here in just a minute. resources that we not only have the resources but as SQF practitioners we need to communicate effectively when we need resources.

Is it people, equipment, facility and being able to have that also financial acumen we spoke to be able to say why and what value it's going to have. Are we going to be able to reduce our cost in some area or prevent a food safety event from occurring or lag in out of spec products because we have results that put product on hold. We also need to lead by example. This is one of the key things when it comes to management. It is not a desk job in food industry. we have to walk the floor. We have to engage frequently. If we don't know what's going on out in the operation, if we're not out there and visible, then we're not committed. so we need to lead by example. We need to also demonstrate and communicate compliance behaviors. What does good look like? So it's not just about that food safety policy and that annual meeting or that monthly meeting that you're having. This is really walking the talk in many different ways and be aing be able to show true management commitment, not just what's on paper. When though we do have to conduct those assessments, we want to look at trends.

So this is great time of the year, right? We've closed the 2025 books. So pull together that annual meeting. If it's typically in July, do it now. Do it again in July. have that past audit nonconformance, have those recurred? have we addressed them? What were our customer complaints? And what are we going to do to improve on those? Were any other non-conforming events? what were your annual GMP and pest control findings? Look through your monthly GMPs. What were the trends? And how are you going to really ensure that you can reduce those findings? I always say when I can walk a facility and find 20 things, we can close those 20 things and then I can walk that facility again and find at least another 10 things. Because once you clear the weeds from the trees, you start seeing other things. You can start refining and not just always tackling the same bigger issues. Sanitation and preop findings, your environmental monitoring. We really want to make sure those trend analysis including supplier compliance really helps drive our improvements.

And just some other key factors that you may need to consider is overall our flows, our design and hygiene of equipment. Do we have the right tools and resources? Also, one we might forget is our service providers. we're paying them to do a service such as our pest control or a chemical provider or sanitation if you're using a third party sanitation. Are they doing the adequate job for us and where can we improve? as well as team culture. So where are your gaps and how can you improve? So from a food safety culture perspective ultimately what we're trying to do is assess where we're at in that spectrum. We're making sure that we're doing that through either surveys, interviews, understanding the current food safety behaviors. We're going to analyze those results and develop strategies to address and improve. Ultimately, when we're creating and assessing that food safety culture, we have to come up with a plan to move that maturity modeling of our culture in the direction in that positive food safety decisions every day. walk the talk to implement and then continue to reassess.

This is again not something you just put a survey out, you put a few plans in place and it's one and done and you forget it. This is every day. This is ongoing and you have to start integrating those into our organizations better. And this is going to be highlighted coming up even more so as we have focused on a even regulatory level looking at food safety culture. So just a few takeaways that we thought might be helpful is setting behavior-based KPIs when it comes to food safety culture. Here are just a few ideas for you guys. such as percent of employees observe correctly washing their hands. not just reduction nonconformances but reduction nonconformances that were linked to a behavioral gap that could be a GMP inspection result. We also could set behaviors around are we getting the engagement? How many number of ideas and suggestions come from employees? Are employees recognized? Are they attending meetings and engaging?

These type of innovative ways to address KPIs outside our standard customer complaints, nonconformance, no recalls will really start shift your organization in the right direction to better prepare your team for change. Elizabeth, so as we've alluded to, there's a Edition 10. It is coming. It is now on the horizon. We have a an a release date, release month. We'll put a date. We're not giving you an official date yet. but we will be talking about this at a at SQF Unites. So, if you haven't been there, I would highly encourage you to. I've heard wonderful things and I get to go this year. So, I am super excited. it is in St. Louis, Missouri. and we are going to talk about those edition 10 topics. So, while you guys don't have a copy of it in your hands, I unfortunately have a copy of it all the time in my hands. We are actively working very, very hard. to get that out to you, to get it into your hands, but we will be talking about the content and what that means and how that's going to be how it's going to affect your site.

So, if you want to learn about Edition 10 and hear from us, I would encourage you, please sign up, come to the conference. It's going to be great beginning of March. so, please come on. We would we would love to see you. and I it will be a great time. We are having some great sessions. a lot of it is focused around Edition 10 and the contents.

Denise Webster: Yeah, I have to say it is one of the best conferences that I go to every year. just I can't speak enough about how well it's pulled together. so just a few more things and then we'll get to a few of your questions you have. if you want to be on the ground floor of where things are shifting right after SQF conference, the global food safety initiative conference and they're going to be looking at it from a more global perspective harnessing AI and really where are the shifts that are coming before you even see them touch any of the code or schemes that you work with. at SCS we are food safety provider of all things SQF and other schemes. So reach out to us if you need audits. We also have our training center. We're excited as soon as that code comes out to offer the SQF conversion course as well as the two-day full implementation training and quality code. if you haven't heard, quality code is one that's going to be focused more and more on your retailers and other customers. So reach out as well as those regulatory trainings that might impact your business.

All right, so we have a few minutes. Elizabeth, let's open it up for Q&A. See what we've got on the docket here.

Elizabeth Tierno: Yeah, so we do have a couple questions. So I've put them in a queue on my other screen. so someone asked, "What is the best way to interview employees when they're nervous to answer, but not because they don't know processing, but more they just get caught off guard by the sudden interview?

Denise Webster: Yeah. Well, one, that's why you do it for practice. I, expect that they're going to be nervous, right? but the more your team does it, the less than they're going to be nervous when it's it's go time. It's it's that Super Bowl with the auditor there. if we're going to do sports analogies, I can do it all day. And ultimately, just let them know, right? Assure them we're prepping for our audit. We want to better understand what you're doing. Can you take me walk me through the process? Right. So, if you're your tone and you're prepping them, they're more apt to be less nervous and we're, and explain again the watts. We're doing this to figure out where we can help you and help close, any gaps as well. That would be my recommendation.

Elizabeth Tierno: It definitely helps to have that conversation with your employees before the auditor does. I had one of my employees, he just started making stuff up and I'm not sure where he started coming up with the things. None of it was true and we're all like, "Stop talking. Please stop talking." So, prep your employees. Hey, you might get interviewed by your third party auditor. Typically, they're going to be like, they want to put that person at ease because they want the real answers. They're not looking to try and trick them. we do train our auditors. I have contact with all of them. So, we're training them not to trick them, but to get those honest answers. And a lot of them go, "Tell me about your job. What do you do?" Your employees, whether they've been there for a week or they've been there for 18 years, they typically know what they do. So, ask them to explain their job. And depending on what you're doing, maybe it's really loud environment and maybe you need to walk away from the line.

So if an auditor is there and they start trying to interview one of your employees be like, "Hey, can you just hold on a second? Let's get someone to fill their position and then we can step away from the machine so they can hear you better." It is absolutely acceptable to do that. So sometimes changing that environment does help and can help the person who's being interviewed. here's one says, "What are the best traits you have seen in a successful internal auditor? I think it's going to depend on your site. Yeah. All right, Denise, go ahead. What were you gonna say?

Denise Webster: Yeah. No, that's a good question. because what makes a good internal auditor, right? maybe one that's not out there trying to police that's more, focused on asking the observation, being able to be patient and stand out there for 20 minutes. I thought I was doing good standing out there for 510. I didn't know I had to stand out there for 20 minutes to get the true behavior. So I learned something today. so you got to pick the right personality for the role. Not everybody can be an internal auditor.

Elizabeth Tierno: And I would agree when you go, okay, where's the internal auditor? It's the same with the third party auditor. You'll have auditors come and some are more successful than others because they are willing to listen to that answer. And sometimes you have need to listen to what they don't say and ask another question. because most often the employees do get it. They understand the programs and what it means, but sometimes it's just asking that other question and being open to how people answer it. Look at the code and don't expect a certain answer because you might know the program, but as the internal auditor, you shouldn't be managing that program. If you are, you should not be doing that internal audit for that part. but see what else is going on. Saying ask those questions and open to what the possibilities are. and we train our thirdparty auditors to do that. Going, you may have seen something that was a best practice at another facility, but that site's still doing it correctly. They're still compliant. So, being open to those things. And I know we have technically run over.

Elizabeth Tierno: I have one question that I just want to touch on. So, someone asked, it's a little bit different. but it says, "As the only QA person and the first person in this position, how do I be more effective?" And I would say, "You're not alone." one thing I will say is your suppliers might be willing to bring you into the facility. The food industry, while it is big, we're not that big. And I had some great suppliers to say, "Hey, can I come in and see your facility?" And I never had anyone say no. so there are lots of resources and lot of different people within your industry that are local that would be willing to help you out and give you that little bit leg up. And all those different free resource sources that we've talked about, take advantage of them. They're there. Look on our website. keep looking around. don't give up. There are a lot of things. You're going to hit roadblocks, especially if it's a first time for a position. don't give up. You're going to hit a roadblock. and keep pushing through. Excellent. That's a that's a great note. I can't add anything more to that.

That's a great way to close. And if there are any other questions that we weren't able to get to, we can always follow up post the webinar. And thank you Elizabeth and SQF for allowing SCS to partner with you today on this. And I can't wait to see everybody in March.

Elizabeth Tierno: Thanks Denise. I had a great time today. Yeah, hopefully everyone comes to you. I'm looking forward to it.